Understanding the FERC Natural Gas Rate Case Process & Rate Filing

March 19, 2025 | Online :: Central Time

0325-ferc-natural-gas

“Very knowledgeable, hands-on experience.” – Principal Manager at DTE

In this one-day program, participants will take a deep dive into the intricacies of the Federal Energy Regulatory Commission (FERC) Natural Gas Rate Case and Rate Filing processes. The agenda will guide attendees through each phase, from pre-filing preparations to the ultimate resolution of the case. Participants will be able to hone their skills in discerning relevant information from general ledgers and craft a representative snapshot of business operations for the filing. With a keen focus on understanding the desired outcome and engaging with stakeholders, attendees will learn to navigate the complexities of rate case schedules and testimony preparation.

The course agenda will also review:

• Strategies for addressing protests and crafting compelling responses
• How to review testimony and dissect key components of a rate filing, including cost of service, return calculations, and operational expenses
• Cost allocation, rate design, and settlement negotiations
• How to advocate effectively during testimony, navigate the hearing process, and articulate a case through written briefs

Register your team of five or more now for discounts starting at 15% off!

Learning Outcomes  

• Review the regulatory framework and procedural requirements of the FERC Natural Gas Rate Case Filing process
• Acquire the skills to gather, scrub, and analyze data to prepare a comprehensive rate case filing
• Develop proficiency in crafting persuasive testimony and rate case schedules to effectively advocate for desired outcomes
• Gain insights into navigating protests, discovery procedures, and engaging with stakeholders throughout the rate case proceedings
• Master the principles of cost allocation, rate design, and settlement negotiations in the context of natural gas rate cases

Wednesday, March 19, 2025 : Central Time

 

Pre-Filing

• Pipeline gathers and scrub data
  • Requires review of?
    • General ledger
    • Form 2s
    • Capital markets data necessary for calculating proposed return on equity
  • Scrub
    • Pipeline determines base period it will use (i.e., 12 consecutive months of actual experience ending no more than 4 months before the rate case is filed)
    • Pipeline reviews base period data to identify items that need to be adjusted for purposes of normalization removal of non-recurring items
    • Pipeline identifies Adjustment Period and Test Period
    • Pipeline identifies known and measurable adjustments to be made for changes that will become effective (e.g., increased labor costs, tax increases)
• Understand desired outcome
• Pipeline meets with customers
• Pipeline prepares tariff changes, justification for the filing, and supporting testimony

Filing

• Pipeline makes the filing
• Public notice and comment period
• Requirements for Interventions and protests
• Answers to Protests, and answers to answers
• Commission Order setting case for hearing and suspending rate increase temporarily and allowing to go into effect afterwards subec to refund
• Motion rates filings under 154.206
• Rehearing/Clarification Requests to FERC

Initial Prehearing Conference

 

Settlement Judge Processes

 

Rolling Discovery

• Review of testimony and rate filing
  • Test period concept
• Four key areas of the rate case
  • Cost of service
    • Rate base
      • Plant
        • What is jurisdictional plant?
        • What to look for
      • ADDA
        • Projecting
        • What to look for
      • Working capital
        • Prepayments
        • Materials and supplies
        • What to look for
      • ADIT
        • Timing difference
        • Credit to rate base
        • What to look for
      • Regulatory assets and liabilities
        • TCJA impacts
        • Other assets and liabilities
        • What to look for
    • Return
      • Cost of capital calculations
        • DCF
        • Cost of debt
        • Capital structure
        • What to look for
    • Income tax allowance
      • TCJA impacts
      • PL19-2 impacts
      • What to look for
    • Operation and Maintenance expenses
      • Labor
      • Material and other
      • Administrative and general
      • Gas costs
      • What to look for
    • Depreciation and net negative salvage expense
      • Economic end life
      • Survivor curves
      • What to look for
    • Taxes other than income
      • Property taxes
      • Payroll taxes
      • Miscellaneous taxes
      • What to look for
  • Cost allocation and rate design
    • Billing determinates
      • Firm
      • Interruptible
      • Reservation/commodity
      • What to look for
    • Cost functionalization
      • Common costs allocation
        • General and intangible plant
        • A&G – KN Method
      • Cost allocation to incrementals/zones
        • Allocation factors
    • Cost classification
    • Straight fixed variable
      • Fixed/reservation
      • Variable/commodity
    • Transmission distance sensitive rate designs
      • Mileage based
        • Cost allocation between mileage and non-mileage
        • Access charge
      • Zone gate
        • Cost allocation between zones mileage and non-mileage
        • Access charge
    • Transmission Postage Stamp rate design
    • Storage rate design
      • Equitable method

Settlement

• Top sheets
  • What are top sheets?
  • What aren’t top sheets?

Negotiations

• Customer vs. Pipeline
• Customer vs. Customer
• Stability vs. Unknown Outcome Litigation

Testimony

• Building your case
• Supporting your case
• Answering
  • Who files
  • What is filed
• Cross-Answering
  • Who files
  • What is filed

Hearing

• Hearing preparation
• Testifying

Briefs

• Initial
• Reply

Initial Decision

• Exceptions

FERC Order on Initial Decision

Glenn Benson, Partner, BakerHostetler 

One of the country’s leading representatives of onshore and offshore oil and gas producers on regulatory matters, Glenn Benson brings 25 years of experience and an uncommon familiarity with the Federal Energy Regulatory Commission (FERC) to his role on the BakerHostetler national Energy Industry practice team. He counsels clients across the energy industry on tariff and contract disputes before FERC, regulatory compliance and enforcement, and the negotiation of commercial transactions, including power purchase agreements, interconnection agreements, pipeline precedent agreements, asset management agreements, and oil and gas purchase and sale agreements.

We will be using Microsoft Teams to facilitate your participation in the upcoming event. You do not need to have an existing Teams account in order to participate in the broadcast – the course will play in your browser and you will have the option of using a microphone to speak with the room and ask questions, or type any questions in via the chat window and our on-site representative will relay your question to the instructor.

• Microsoft recommends downloading and installing the Teams app if possible. You may also use the Edge browser or Chrome.
• You will receive a separate email with a unique link to a personalized landing page which will include links to join all sessions of this event.
• If you are using a microphone, please ensure that it is muted until such time as you need to ask a question.
• The remote meeting connection will be open approximately 30 minutes before the start of the course. We encourage you to connect as early as possible in case you experience any unforeseen problems.

Please Note: This event is being conducted entirely online. All attendees will connect and attend from their computer, one connection per purchase. For details please see our FAQ

If you are unable to attend at the scheduled date and time, we make recordings available to all attendees for 7 days after the event

REGISTER NOW FOR THIS EVENT:

Understanding the FERC Natural Gas Rate Case Process & Rate Filing

March 19, 2025 | Online

Your registration may be transferred to a member of your organization up to 24 hours in advance of the event. Cancellations must be received on or before February 14, 2025 in order to be refunded and will be subject to a US $195.00 processing fee per registrant. No refunds will be made after this date. Cancellations received after this date will create a credit of the tuition (less processing fee) good toward any other EUCI event. This credit will be good for six months from the cancellation date. In the event of non-attendance, all registration fees will be forfeited. In case of conference cancellation, EUCIs liability is limited to refund of the event registration fee only. For more information regarding administrative policies, such as complaints and refunds, please contact our offices at 303-770-8800

Credits

EUCI is accredited by the International Accreditors for Continuing Education and Training (IACET) and offers IACET CEUs for its learning events that comply with the ANSI/IACET Continuing Education and Training Standard. IACET is recognized internationally as a standard development organization and accrediting body that promotes quality of continuing education and training.

EUCI is authorized by IACET to offer 0.7 CEUs for this event.

Verify our IACET accreditation

Who recognizes IACET Credits?

Requirements for Successful Completion of Program

Participants must log in and be in attendance for the entirety of the course to be eligible for continuing education credit.

Instructional Methods

PowerPoint presentations, interactive group exercise, and group discussion will be used during this course.

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Upon successful completion of this event, program participants interested in receiving CPE credits will receive a certificate of completion.

Course CPE Credits: 8.0
There is no prerequisite for this Course.
Program field of study: Specialized Knowledge
Program Level: Basic
Delivery Method: Group Internet Based
Advanced Preparation: None

EUCI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: www.nasbaregistry.org

 

Who Should Attend

• Traders, marketers, natural gas utilities employees, and power generation employees that utilize natural gas supply
• Managers, members of the financial community, compliance function employees, in-house and law firm attorneys, and anyone else interested in or who has a need to know about the laws governing FERC and its rules, policies, and procedures that affect the natural gas and LNG industry
• The course will benefit those seeking a basic knowledge of FERC, those desiring a refresher course or a broader context of FERC knowledge, and those seeking insight on current agency proceedings involving natural gas and LNG